New York's Appellate Division has removed one of the most powerful tools the Manhattan District Attorney's office has used over the past decade to seize artworks and repatriate antiquities. In a decision overturning Justice Drysdale's April 2025 ruling, the court held that Penal Law section 450.10 - the provision under which the DA obtained a 2023 warrant for Egon Schiele's 'Russian Prisoner of War' (1916) at the Art Institute of Chicago - cannot be used to resolve 'complicated, disputed issues of ownership' and is reserved for the straightforward recovery of stolen property. The ownership dispute between the Art Institute and the heirs of Fritz Grünbaum, the Austrian entertainer who died at Dachau in 1941, now moves to federal civil court, where proceedings were stayed. The ruling casts a shadow over the DA's wider practice: the office has cited more than 100 turnover orders returning thousands of antiquities and artworks under the provision, with a recent press release putting the total above 6,200 artefacts.